COSHH stands for the Control of Substances Hazardous to Health Regulations and is a series of regulations that every business must follow to protect its workers, customers and the general public from the harmful effects of hazardous substances. For obvious reasons this legislation is particularly applicable to those in the decorating business.
The aim of the following guide is give you a general understanding of what COSHH covers, how to calculate the risks and what action to take.
Exposure to hazardous substances can occur by inhalation, contact with the body and eyes or through ingestion. Effects from exposure to a hazardous substance can last for a few minutes, months or be permanent and can result in illnesses such as eye irritation, asthma, dermatitis, lung disease or even cancer.
There are four common types of hazardous substances and although all four are probably not directly relevant to the work of a decorator, you should make sure you are aware of all potential hazards.
- Substances used directly in work activities. For decorators this includes products such as paints, adhesives and cleaning agents. If a product is hazardous, it should be clearly labelled and the supplier must provide a safety data sheet.
- Substances generated during work activities such as fumes from soldering.
- Naturally occurring substances such as grain dust.
- Biological agents such as bacteria and other micro-organisms.
Some hazardous substances are covered under separate regulations. For example, asbestos comes under the Control of Asbestos at Work Regulations 2002 (CAW) and the Asbestos (Licensing) Regulations 1983; whilst lead comes under The Control of Lead at Work Regulations 2002.
COSHH helps employers follow good management by setting out eight basic measures that should be taken to assess and control exposure.
In order to minimise and control the exposure to hazardous substances you should first carry out a risk assessment. This can be done by you or by a qualified individual or company and should ideally include employees or their safety representative. Employees must also be made aware of the results of the assessment.
When carrying out an assessment you should think about the following:
- Substances that are supplied to you.
- Substances produced by your work such as fumes, vapours, dusts.
- Final products and waste management.
You can get help in identifying hazardous substances through trade associations, your local Business Link or the Health and Safety Executive (HSE). The HSE also has a microsite dedicated to COSHH which you can find here.
When assessing the risks you need to think about what health problems these substances can cause. To do this, ask yourself the following:
- How much of the hazardous substance is in use or produced by the work activity and how can people be exposed to it?
- Who could be exposed to a hazardous substance and how often? (Remember this should include everyone that could be exposed, not just employees.)
- Can the substance be swallowed or absorbed through the skin?
Once a risk has been identified you need to decide on what action should be taken to remove or reduce the hazard and protect all who could be affected. This should include employees as well as the general public.
If you have more than five employees then you are legally required to keep a record of the main findings of the risk assessment. This assessment should also record what actions your employees and others must take to make sure the risks posed by the hazardous substance are controlled adequately.
COSHH requires you to prevent exposure to substances hazardous to health if it is reasonably practicable to do so. In other words if it does not mean a complete change to your working practices then you should try to eliminate a hazardous substance. You might for example replace it with a non-hazardous substance, such as changing from a solvent-based paint to a water-based one.
If prevention is not possible then steps must be taken to adequately control the risk:
- Use appropriate working practices, systems or controls which might minimise the amount of material produced or used.
- Control the exposure at source; for example by using exhaust ventilation to prevent the substance being breathed in.
- Reduce the number of people exposed and the duration of their exposure to a minimum.
- Provide personal protective equipment (PPE) such as face masks, respirators and protective clothing. This must be a last resort and not a replacement for other control measures.
It is your duty as employer to ensure that all control measures are followed and defects reported. This also means that control measures must be maintained sufficiently so that they perform as they are intended. For example, equipment such as exhaust ventilation, respiratory and other such PPE should be regularly tested.
If your risk assessment identifies the following, then legally you must measure the concentration of hazardous substances in the air that workers breathe:
- There could be serious risk to health if control measures fail or deteriorate.
- Exposure limits may be exceeded.
- Control measures may not be working correctly.
However, this is not necessary if you are already preventing or adequately controlling exposure, for example by using an alarm which detects hazardous substances.
Records of any exposure monitoring must be kept and maintained for at least five years.
Under COSHH you are also required to carry out a 'health surveillance' if an employee is exposed to a substance that has been identified as hazardous or linked to a particular disease.
A health surveillance can involve examination by a doctor, nurse or a trained supervisor who could check an employee's skin for dermatitis or assess any breathing difficulties.
To comply with COSHH you must keep a simple record of any health surveillance you carry out and make sure that this is kept for at least 40 years.
No matter how much planning or preparation goes into a job, accidents do and will happen so you must plan your response to an emergency involving hazardous substances before it happens.
This means preparing procedures to respond immediately and ensure that information regarding the emergency is available to those who need it. Safety drills should also be carried out so that people know exactly what to do and when.
All employees must be given sufficient information, instruction and training on a regular basis. Ideally this should include:
- The names of the substances they work with and the risks associated with these substances.
- The findings of any risk assessment you carry out.
- How to use any PPE and protective clothing you provide.
- Results of any exposure monitoring or surveillance you have carried out (this must not include an individual employees' name).
- Which emergency procedures should be followed. For example if a person using a solvent-based paint complains of running eyes, headache and nausea, they could be suffering from solvent intoxication. In this case they must stop work immediately and get plenty of fresh air.
Your health and safety responsibilities do not end once you have finished with a hazardous product or substance. Legally you are responsible for the correct disposal or recovery of the hazardous substance as well.
There are also additional requirements for the disposal or treatment of waste and containers used for materials with hazardous characteristics. These are termed 'special wastes' and include solvent-based paint. Information on the manufacturer's safety data sheet will identify if the waste is 'special'.
For more information and to make sure you are up to date with the latest regulations please check with the publications and contacts listed below.
COSHH: A brief guide to the Regulations
What you need to know about the Control of Substances Hazardous to Health Regulations 2002 You can download this guide from the Health & Safety Executive (HSE) website here
- Health & Safety Executive Infoline. 0845 345 0055. www.hse.gov.uk
- Environment Agency Helpline. 08708 506 506 www.environment-agency.gov.uk
- Environment Agency Incident Hotline. 0800 80 70 60
The above information is correct at the time of writing (July 2009) but please check the details are up-to-date with the various organisations listed.
The contents of this guidance are for information only and no guarantee, representation or warranty of any kind is given (whether express or implied) in relation to any of the information, advice or opinions expressed in it. Whilst ICI Paints AkzoNobel have made all reasonable efforts to ensure that statements appearing in this guidance are accurate, ICI Paints AkzoNobel disclaims all liability and responsibility arising from any reliance placed on the information, advice and opinions contained in this guidance. ICI Paints AkzoNobel reserves the right to make any amendments or alterations to this guidance at any time, without notice.